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    General Provisions

    This Personal Data Processing Policy (hereinafter referred to as the “Policy”) defines the procedures for processing and protecting personal data of individuals enrolled in the online manicure school of Elena Milovanova, a structural subdivision of Individual Entrepreneur Milovanov D.V. (OGRNIP 317237500145811, 352508, Krasnodar Region, Labinsk, Revolyutsionnaya St., 367/1, Office 15), as well as visitors of the website www.rusmanicure.online (hereinafter referred to as the “Operator”). The Policy is developed in accordance with the legislation of the Russian Federation and international data protection standards.

    Legal Grounds

    This Policy is based on:

    • The Constitution of the Russian Federation;

    • Federal Law No. 152-FZ dated 27.07.2006 “On Personal Data”;

    • The Education Law of the Russian Federation;

    • The EU General Data Protection Regulation (GDPR);

    • Other regulatory legal acts of the Russian Federation and international agreements.

    Terms and Definitions

    • Personal Data (PD) — any information relating directly or indirectly to an identified or identifiable individual (data subject).

    • Processing of Personal Data — any action or set of actions performed with PD, including collection, recording, systematization, storage, clarification, extraction, transfer, anonymization, blocking, deletion, destruction.

    • Operator — Individual Entrepreneur Milovanov D.V., performing PD processing.

    Purposes of Personal Data Processing

    The Operator processes personal data for the following purposes:

    • Conclusion and execution of contracts (offers) for educational services.

    • Accounting of students and compliance with educational legislation requirements.

    • Communication and informing students via the website and messengers.

    • Compliance with tax, labor, and other legal requirements.

    • Protection of rights and legitimate interests of the Operator and data subjects.

    Types of Processed Personal Data

    Depending on the category of data subjects and type of educational program, the Operator processes:

    • Full name;

    • Contact phone number;

    • Email address;

    • Other information voluntarily provided by the data subject.

    Legal Basis for Processing Personal Data

    Processing of PD is carried out based on:

    • A contract with the data subject or their legal representative;

    • Consent of the data subject to the processing of their personal data;

    • Requirements of federal law;

    • For users from the European Union — based on GDPR, with explicit and voluntary consent obtained.

    Procedure and Conditions for Processing Personal Data

    • Processing is performed both with and without the use of automation tools.

    • Processing is limited to the extent necessary to achieve declared purposes and strictly according to the type of educational programs (professional or additional education).

    • The Operator implements all necessary legal, organizational, and technical measures to protect PD from unauthorized access, destruction, alteration, blocking, copying, dissemination, and other illegal actions.

    • Access to PD is granted only to authorized employees who have signed non-disclosure agreements.

    Transfer of Personal Data to Third Parties

    Transfer of PD is permitted only:

    • With written consent of the data subject;

    • In cases stipulated by Russian law (e.g., tax authorities, pension fund);

    • When fulfilling contractual obligations (e.g., ordering diplomas via printing services);

    • For international data transfers, including EU users, in compliance with GDPR requirements.

    Retention Periods for Personal Data

    • Paper personal files are stored according to educational legislation timelines.

    • Electronic databases store PD until processing purposes are achieved, consent is withdrawn, or legally required periods expire.

    • Data of EU citizens (GDPR) are stored and processed in accordance with GDPR, and may be transferred outside the EU only under appropriate conditions, including consent.

    Rights of Data Subjects

    Data subjects have the right to:

    • Access their personal data;

    • Request correction, blocking, or deletion of their personal data;

    • Withdraw consent for data processing;

    • Appeal to Roskomnadzor or courts in case of rights violations;

    • Under GDPR, have data portability and the right to be forgotten.

    Withdrawal of Consent

    Data subjects may withdraw consent by submitting a written request to the Operator at the address on www.rusmanicure.online or via personal account/messenger.

    Final Provisions

    • The Policy is publicly accessible. The current version is posted on www.rusmanicure.online.

    • All amendments take effect upon publication of a new version.

    Date of update: April 2025.

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